Dear Jennifer:
Thank you for inviting public comments on the proposed Forest Stewardship Plan (FSP) for the Johnstone Strait portion of TFL 47. To summarize the detailed points below—this FSP needs to be revised and re-issued. The rate of cut in the Johnstone Strait portion of TFL 47 should be reduced to address the known effects of climate change and biodiversity loss. The exact loss of harvestable timber due to climate change induced fire, drought and insect infestations may not be known, but there is abundant science showing the trends and suggesting timelines.
1) This area is considered part of the Great Bear Rainforest. Much of the proposed Forest Stewardship Plan (FSP) refers to the Great Bear Rainforest Order (GBRO). The public in BC and well beyond the borders of BC expects this “global treasure” to have a high degree of protection. This proposed FSP fails to fulfill the expectations of the public or what is highlighted in the following government of BC website from which I quote:
“The Great Bear Rainforest is a global treasure that covers 6.4 million hectares on British Columbia’s north and central coast—equivalent in size to Ireland. All British Columbians have a stake in protecting it. The historic agreement that secures the future of the Great Bear Rainforest means more old- and second-growth forest will be protected, while still ensuring opportunities for economic development and jobs for local First Nations… The 2016 Great Bear Rainforest Land Use Order and Great Bear Rainforest (Forest Management) Act will conserve 85% of the forest and 70% of old growth over time, achieving a high level of ecological integrity. Learn about this incredible place and the historic agreement that will conserve this area for generations to come.”
“The Great Bear Rainforest Announcement outlines the forest practices for the area and increases the amount of protected old-growth forest from 50% to 70%. Eight new areas covering almost 295,000 hectares will be off-limits to logging with 85% (3.1 million hectares) of the forest protected and 15% (550,000 hectares) available for logging to support local jobs and strengthen the region’s communities.”
“The amount of habitat protected for marbled murrelet, northern goshawk, grizzly bear, mountain goat, and tailed frog will increase as each new reserve is developed.”
It is not within the scope of an FSP to plan for use of the trees cut beyond the logistics of planning and cutting. But with current logging techniques and equipment, road building and cutting create minimal local employment. So far as we know there are no sizeable sawmills or other processing facilities for logs in the Johnstone Strait portion of TFL 47. It is likely that the situation in this portion of TFL 47 is similar to the portion of TFL 47 on Quadra Island where we live. Estimates based on reliable data are that 80 to 90 percent of the trees felled for TimberWest on Quadra get exported as raw logs, and the number of local people employed is quite small.
2) Much of the Johnstone Strait portion of TFL 47 is on 4 islands: Sonora, East Thurlow, West Thurlow and Hardwicke. Small islands are inherently fragile. If an event such as fire or logging causes large habitat loss in a short period of time, then it is hard for certain species to survive or re-populate the island. Climate change is currently accelerating. In the context of longer droughts, increased insect infestations and more winter storms causing blowdown beside cut blocks, it is likely to get harder and harder for many species to recover. Many species of animals and plants are now at risk of being extirpated from these islands. As an example of what has taken place, in the 27-year period between 1990 and 2015, 3818 hectares of 8133-hectare West Thurlow Island were cut. E.g. 47 percent of the entire area of the island. Most of that cutting (3369 hectares) occurred in the 19 years between 1997 and 2015.
It seems to local observers such as ourselves that the promises of protection of forests in eight areas of the Great Bear Rainforest come at the unstated cost of decimating other parts of the Great Bear Rainforest such as the areas of Johnstone Strait at issue in this FSP. Apparently the areas in the FSP at issue are not part of the eight new areas outlined in the Great Bear Rainforest Announcement. If some areas of the Great Bear Rainforest are in need of protection and worthy of protection, then why does this not apply to the whole area of the Great Bear Rainforest? How does removing 47 percent of the forested area of a small island over a period of 27 years jive with the commitment to have 85% of the eight new areas off-limits to logging? Most members of the BC public would perceive the Johnstone strait area as wilderness in need of protection, not only the portions of the Great Bear Rainforest north of this area.
3) The proposed FSP provides no mapping of the habitat of species at risk listed under federal species at risk legislation including the Marbled Murrelet. Mapping that interested residents of the Discovery Islands have managed to obtain shows that TimberWest has already logged parts of designated critical habitat for federally listed species at risk on Sonora, Hardwicke, East and West Thurlow Islands and the mainland portion of TFL 47. The proposed FSP acknowledges the Great Bear Rainforest Order (GBRO) requirements for certain wildlife species and red- and blue-listed plant communities and states that it will abide by those GBRO objectives. The FSP also acknowledges the Forest and Range Practices Act requirements for red- and blue-listed animal species. BC is in the midst of developing a Biodiversity and Ecosystem Health Framework. We quote from Bonnie Brownstein’s response to the Biodiversity and Ecosystem Health Framework:
“[B]iodiversity and ecosystem health in many parts of BC are so threatened by the last many decades of large scale forestry that truly radical changes are needed in short order. Your own mandate letter (Nathan Cullen) from Premier David Eby says that short-term thinking in land management has led to ‘exhausted forests’. It is no secret that ‘exhausted forests’ are part of a larger collapse which is starting to endanger the future of the human population of BC.”
The FSP should be revised to map the habitat of federally listed species at risk and outline a plan to protect this habitat. No wildlife habitat areas (WHAs) have been outlined in the area covered by this FSP for any of the red or blue listed species except the goshawk. This FSP should map out WHAs and contain specific directions to protect the habitat of all of these species.
4) There is no direct mention in this proposed FSP of the spraying of glyphosate although Section 9, specifically 9.3.1, 9.3.2 and 9.3.3, do concern alder populations. If current practices continue glyphosate will be sprayed on all cut blocks in the Johnstone strait portion of TFL 47. This cannot help but have a huge negative impact on existing red- and blue-listed plant species. This FSP contains the following language: “The holder of an FSP is required, on cutblocks harvested under an FSP, to establish a free growing stand…” In other words—get rid of the deciduous trees and shrubs that are perceived to hamper the growth of crop trees. This thinking is based on outdated science. This requirement also conflicts with the BC government’s move in the direction of fostering biodiversity and ecosystem health, and doesn’t take into account the increased risk of fire in our rapidly changing coastal climate. The deleterious impacts of glyphosate spraying on red- and blue-listed plant species and its impact on reducing populations of fire-resistant deciduous trees such as red alder need to be addressed in a revised FSP. Ideally glyphosate spraying should be eliminated in favour of manual removal of non-crop species where this is considered essential. Manual removal would generate employment!
5) This proposed FSP contains this sentence under “Objectives for old forest maintenance and recovery” “(1) Maintain landscape level biodiversity as follows: (a) for each site series group in the order area, maintain a distribution of forest stand ages that will achieve the old forest representation targets listed in Column A in Schedule G by no later than 2264;” No Schedule G has been provided to the public along with this FSP, so the public doesn’t know what targets are contained in Column A. It is nonsensical to give a timeline of 240 years to maintain old forest. How about conserving all old forest that is left, no matter how small the patches of such trees are or how few old trees are left in patches that mainly contain younger age classes? In a time of increasingly long droughts there are some predictions that Vancouver Island will be sparsely forested in future. Forestry companies have already logged old forest on the islands in Johnstone Strait to below the “high risk” level of 10 percent, a critical level set out in the Gorley-Merkel report A New Future For Old Forests.
According to current mapping of old forest priority deferral areas, Hardwicke Island is down to 8 percent old forest, East Thurlow and West Thurlow Islands are both down to 6 percent, and Sonora is down to 4 percent. Gorley and Merkel’s recommendation #6 (page 56) implied an immediate deferral on logging of old forest in the CWHxm2 biogeoclimatic zone variant in the Thurlow Landscape Unit, which covers most of the land in the Johnstone Strait portion of TFL 47. It is known that TimberWest logged old forest (age class 8 near Knox Bay on West Thurlow Island in 2014). It has also done so in other parts of the Johnstone Strait portion of TFL 47, including on Sonora Island. TimberWest should release to the public any mapping it has access to of old forest in the Johnstone Strait portion of TFL 47, as it has already done for Quadra Island. The final FSP should acknowledge the current old forest deferral areas and indicate whether or not they have been approved. TimberWest should state in its FSP that it will not log or degrade any remaining old forest or cut individual old trees on any of the islands in the Johnstone Strait portion of TFL 47. It has already done this for the SMZ 19 portion of Quadra Island.
6) The only mention of climate change in this proposed FSP is “The potential effects of climate change have been considered in the development of this FSP and in particular, the development of the stocking standards.” Facts that have been known by the Ministry of Forests for more than a decade are ignored seeing as this is the only mention of climate change in the whole document. Climate change is increasing the risk of forest fires. In 2023 the area of BC that burned far outstripped any previous year. Older trees are more resistant to fire than young trees. Logging provides the conditions for fires to happen in the form of increased temperatures in clearcuts, slash piles and young plantations. Fires in some areas are becoming difficult to impossible to control (Read Fire Weather by John Vaillant). Climate change is also increasing the impact of insect infestations which both reduce timber supply and increase forest fire potential. The proposed forest management plan information package that includes the Johnstone Strait portion of TFL 47 states: “…given the current scientific understanding, it is not yet possible to make reasonable quantitative predictions about the impact of climate change on timber supply. Therefore, the base case will not include specific accounting for climate change projections.” Talk about sticking one’s head in the sand! We ask that the rate of cut in the Johnstone Strait portion of TFL 47 be reduced to mitigate the known dangers of climate change and the current extinction crisis.
7) The map for Sonora Island provided in the proposed FSP doesn’t mention the existence of the Thurlow Special Forest Management Area. This 324-hectare area was deleted from TFL 47 in 2016, and is designated as a future ecological reserve. Years of advocating by residents of Sonora Island resulted in this boundary change. This FSP needs to clearly indicate that this future ecological reserve is not part of TFL 47. Residents of the Discovery Islands will be watching to ensure that the Thurlow Special Forest Management Area does not get logged.
Yours Sincerely,
Bonnie Brownstein, Ray Grigg and Kris Wellstein on behalf of The Sierra Club of BC, Quadra Island Group
